F. No. 370142/25/2017-TPL
Government of India
Ministry of Finance
Department of Revenue
Central Board of Direct Taxes
New Delhi, Dated 6th October, 2017
Subject: Framing of rules in respect of Country-by-Country reporting and furnishing of master file – comments and suggestions-reg
In keeping with India’s commitment to implement the recommendations of 2015
Final Report on Action 13, titled “Transfer Pricing Documentation and Country-byCountry
Reporting”, identified under the OECD Base Erosion and Profit Shifting (BEPS)
Project, section 286 of the Income-tax Act, 1961 (‘the Act’) was inserted vide Finance Act,
2016, providing for furnishing of a Country-by-Country report in respect of an
international group by its constituent or parent entity. Section 92D of the Act was also
amended vide Finance Act, 2016 to provide for keeping and maintaining of Master File by
every constituent entity of an international group, which was to be furnished as per rules
prescribed in this regard.
2. Consequent to the aforesaid amendments to the Act, it is proposed to insert rules
10DA, 10DB and form nos. 3CEBA to 3CEBE in the Income-tax Rules, 1962 (‘the
Rules’), laying down the guidelines for maintaining and furnishing of transfer pricing
documentation in the Master File and Country-by-Country report. In this regard, the
following guidelines are proposed to be prescribed:
2.1 The following rules 10DA and 10DB are proposed to be inserted in the Rules after
the existing rule 10D:
“Information and documents to be kept and maintained under proviso to sub-section (1) and to be furnished in terms of sub-section (4) of Section 92D
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